ML20027A351

Lakeshore Citizens for Safe Energy Responses to the Wi Elec Pwr Co'S First Set of Interrogs. Defines Increased Worker Activity Re Spent Fuel Pool Activities

ML20027A351
Person / Time
Site:	Point Beach
Issue date:	10/26/1978
From:	Estes J LAKESHORE CITIZENS FOR SAFE ENERGY
To:
References
NUDOCS 7811200268
Download: ML20027A351 (4)

Text

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10/26/78 h

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UNITED STATES OF AMERICA g7 NUOLE AR REGULATORY COMMIS3 ION In the Mat'ter .of Wisconsin Electric Power Company araendment to License Nos. DPR-24 & Docket Nos 50-266

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50-301 LAKESHORE CITIZENS FOR SAFE ENERGY RESPONSES TO THE WIS00NSIN ELECTRIO POWER COMPANY' S FIRST SET OF INTERROG ATORIES CONTENTIONS:

3b-1 Intervenors believe that worker activity will increase in these three tasks; First, the removal of the old racks and the re-filling of new racks will require increased .-

"over the pool" and "in the pool" activity. Secondly,.

we understand that some of the spent fuel assemblies may be moved about in the pool - from one storage lhication ,

to another, - af ter removal from the core to assure that the outermost storage positions (those nearest the walls) will be the coolest. Thirdly,. we believe the increa' sed ?.

number of stored assemblies will require more monitoring.

activity by the workers.. (D., Estes)

L 3b-2 Intervenors believe the SFP coolant water suction pipe has no protective screening. Any of these activities '

mentioned in 3b-1 requires increased worker activity "o'rer the pool". Any item used by the worker which could drop  !

( into the pool might be drafn into the suction pipe and catise a bb ekage. We concede that worker activity probably would not endanger the " filling"' pipe.

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3d-l " Increased' worker activity" would include: re-positioning spent fuel assemblies after removal from the core (moving

.them from one storage loca. tion to another); monitoring the spent fuel for leaks or coirosion..

3d-2 A)' Volume of SFP co61 ant water might be lost due to :

- worker accident: aropping loads onto piping or into ,

the SFP and thereby breaking the. pool liner

- pump or pipe leaks caused by material drawn into the '

SFP coolant water loop through the un-sc.reened suction pipe B&C) Loss of service' water pumps and loss of volume of service water through the heat exchangers is not likely as a result of increased worker activity - it is., however, possible that increased worker activity would allow a  !

greater chance of worker sabbotage to these components. l 3e-1 " Increased worker activity" includes the increased monitoring necessitated by the increased number of stored assemblies. '

3e-2 Workers can make mistakes, workers can cause accidents, u workers can intentionally cause damage.. The more man- l hours spent in and around the SFP, the greater is the risk of' accident or sabbotage.

5 -1 Pool failure (leakage) could result from: worker sabbotage,,

seismic events, falling aircraft. -

5 -2 The expanded storage, necessitating increased worker activity. will provide for greater chances of worker accidents and sabbotage. It may also offer a more, at, tractive -target

?for " terrorist attacks". .

l 6- 1 " Increased activity" refer to increased worker activity. }

6- 2 See 3d-2A L

(3) .

9-1 1 Loss of SFP coolant water by leakage.

2 Loss of SFP coolant water by pump breakdown.

3 Leakage or corrosion of the stored spent fuel assemblies. i 4 Sabbotage or threatened sabbotage. '

9-2 Increased worker activity may lead to greater accident risk and sabbotage risk. Increased length of storage increases the corrosion possibilities and the increased number of ,

stored assemblies may increase the attractiveness of the  ;

site for terrorist activities.

9-3 Plans are outdated as they contain resources such as ,

physicians who are no longer present in the community. In

( a disaster situation, Two River's Community Hosp. would not be able to handle mass emergencies in their one isolated room.-

Further, local law enforcement agencies and civil defense per sonal are unaware of the assistance that they will be required to give during such an occurence, whether it r be medical or an evacuation procedure. Further,.the emer6ency

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plan has never been tested.  !

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I-CERTIFICATE OF SERVICE t

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• i Marshall E. Miller, Esq., Chairman .

Atomic Safety and Licensing Board

-U S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Emmeth A. Luebke Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Paul W. Purdom 245 Gul

(' ' Radnor,ph Hills Road Pennsylvania 19087 Patrick W. Walsh Esq.

Assistant Attorne,y General State of Wisconsin Department of Justice 114 East State Capitol Madison,,WI 53702 George F. Trowbridge, Esq.

18000 M. Street, H. W.

Washington, D. C. 20036 Bruce A. Berson Counsel for NRC $taff U1 S. Nuclear Regulatory Commission Washington D. C. 20555 m

Docketing and Service Section Office of the Secretary (.3)

U. S. Nuclear Regulatory Commission Washington, D. C. 20555 o

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.esho p Citizens for Safe Energy '

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